Doing Business with Ginnie Mae

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Related-Party Document Custodians

Related-party document custodians, defined as either the Issuer acting as the document custodian (self-custody) or an affiliate of the Issuer acting as the document custodian, are subject to additional requirements. These requirements include:

  • Self-custody:

    The institution must maintain custody of Ginnie Mae documents in a trust department physically separate from the servicing area. The trust must also maintain separate personnel, files and operations.

    The institution must obtain prior approval from its primary regulator to exercise fiduciary powers, which include ordinary trust services, such as personal trust services, personal representative services (executor), guardianship, custodian services and/or investment advisory services offered to the public. The fiduciary powers may not be limited to maintaining custody of documents for Ginnie Mae Issuers.

  • Affiliated document custodian:

    An institution must either (a) meet all of the requirements of Section 13-2(A) of the Ginnie Mae Guide and maintain custody of the Ginnie Mae documents in a separate trust department or, (b) if Ginnie Mae documents are not maintained in a separate trust department, provide evidence satisfactory to Ginnie Mae that the Issuer and the affiliated custodian are vertically independent.

The document custodian function must be subject to periodic review and inspection by the primary regulator.

Last Modified: 10/14/2020 12:01 AM